High Consequence Dangerous Goods and Security Plans

As dangerous goods experts, we often talk about the necessity to prevent the risks that might occur during normal conditions of transport. Unfortunately, these are not our only concerns: in the world we live in we must also pay attention to potential risks posed by the theft and misuse of the most hazardous goods by ill-intentioned individuals against people, property or the environment. These are known as High Consequence Dangerous Goods, and their threats are addressed by the implementation of Security Plans.

High Consequence Dangerous Goods are defined as those which have the potential for misuse in a terrorist event. As a result, severe consequences might ensue: mass casualties, mass destruction or mass socio-economic disruption.

Examples of high consequence dangerous goods include most explosives, toxic substances of packing group I, infectious substances of category A, toxic gases, desensitized explosives and radioactive material above a certain transport security threshold. Other substances and objects might also be considered high consequence dangerous goods depending on the mode of transportation, hazardous properties, packing group and quantities that are shipped.

For air transport, a complete list of high consequence dangerous goods is provided on Subsection 1.6. Similar, but different lists are provided on Subsection 1.4.3 of the IMDG Code for maritime transport, Subsection 1.10.3 of the ADR for road transport, and Subsection 1.10.3 for railroad transport of dangerous goods. In the case of the United States, the equivalent list is found on Section 172.800 of the 49 CFR, the American national regulation for the transport of dangerous goods.

All the participants engaged in the transport of high consequence dangerous goods must adopt, implement and comply with a Security Plan that addresses the measures to take in order to minimize security risks. Security plans must include the following elements:

Specific allocation of responsibilities to competent and qualified persons.

Records of the dangerous goods or types of dangerous goods transported.

Effective and up-to-date procedures for reporting and dealing with security threats, breaches of security and security-related incidents.

Procedures or the evaluation, testing, periodic review and update of security plans.

Measures to ensure the physical security of the transport information contained in the plan.

Measures to ensure that the distribution of information relating to the transport operation contained in the security plan is limited, as far as possible, to only those who need to have it.

In the case of radioactive material, the provisions agreed by the International Atomic Energy Agency (IAEA) must be applied, particularly those of the Convention on Physical Protection for Nuclear material and the IAEA circular on The Physical Protection of Nuclear Material Facilities.

The use of tracking methods to monitor the movement of high consequence dangerous goods and equipment to prevent their theft is encouraged in the regulations, as long as their application never jeopardizes the emergency response in case of an incident.

As usual, all agents must check and comply with the existing local laws and regulations which dictate additional requirements regarding security.